ML19332A843
| ML19332A843 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 09/16/1980 |
| From: | Laverty J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8009180469 | |
| Download: ML19332A843 (37) | |
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09/16/80 g
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In.the Matter of
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Docket No. 50-142 THE REGENTS OF THE UNIVERSITY
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(Proposed Renewal of Facility 0F CALIFORNIA
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License)
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(UCLA Research Reactor)
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NRC STAFF'S POSITION ON CONTENTIONS OF COMMITTEE TO BRIDGE THE GAP A.
Introduction Pursuant to a notice published in the Federal Regis'ter on April 25, 1980, the Committee to Bridge the Gap (CBG or Petitioner) filed a timely petition for leave to intervene requesting that a hearing be held and that Petitioner be admitted as a party to such hearing on the application of the Regents of the University of California (Licensee) for renewal of the operating license for the UCLA Research Reactor.
On July 21, 1980, the Atomic Safety and Licensing Board (Licensing Board cr Board) assigned to the proceeding issued an order scheduling a prehearing conference in the matter for September 18, 1980.
Pursuant to Petitioner's request, the prehearing conference was rescheduled for September 25, 1980 in a Licensing Board Order issued on August 11,'1980.
The Licensing Board's August 11 Order provided that Petitioner could, if it so desired, supplement its petition to intervene by August 25, 1980.
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to such _ supplement were due to be filed by the Licensee on September 9,1980 and by the f1RC Staff on September 17, 1980.
In accordance with the Board's Order and as pemitted by 10 CFR.6 2.714(b), Petitioner filed, on August 25, 1980, a supplement to its petition to intervene setting forth the contentions it wishes to have admitted as issues.in the proceeding. The f1RC Staff's (Staff) response to that supplement and position on the admissibility of Petitioner's proffered contentions is set forth below.E B.
flRC Staff's Position on Admissibility of Contentions 1.
Standards for Admissibility of Contentions As a general matter, for proposed contentions to be admissible they must comply with the requirements of 10 CFR 6 2.714 and applicable Commission case law and raise genuine issues applicable to the facility under consid-era tion.
See, e.g., Duquesne Light Company, et al. '(Beaver Valley Power Station, Unit 1), ALAB-109, 6 AEC 243, 245 (1973); Iowa Electric Light &
Power Company, et al. (Duane Arnold Energy Center), ALAB-108, 6 AEC 195,196 (1973); florthern States Power Company (Prairie Island fluclear Generating Plant, Units 1 & 2), ALAB-107, 6 AEC 188,194, aff'd, CLI-73-12, 6 AEC 241, (1973), aff'd, BPI v. Atomic Energy Commission, 502 F.2d 424 (D.C. Cir.
19 74).
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The 'WRC Staff's Response to Petition to Intervene of the Committee to Bridge the Gap" was filed on June 11, 1980.
In that document the Staff expressed its view that CBG had established the requisite interest and standing to intervene in the captioned proceeding and had satisfied the
" aspects" requirement of 10 CFRl6 2.714.
Pending submission of the supplement to the petition to-intervene which.is the subject of the instant response, the Staff reserved judgment on whether CBG satisfied the contention requirement of 10 CFR $ 2.714(b).
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- 10 CFR 9 2.714(b). requires that a list of contentions which an intervenor seeks to have litigated be filed along with the bases for-those contentions
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set forth with reasonable specificity.
A contention must be rejected where:
-t (a) it constitutes an attack on applicable statutory require-ments; 3
(b) it challenges the basic structure of the Commission's regu-latory process or is an attack on-the regulations; (c) it is nothing more than a generalization regarding the inter-I venor's views of what applicable policies ought to be; (d) it seeks to raise an ig tion in the proceeding pue which is not proper for adjudica-or does not apply to the facility in question; or l '
(e) it seeks to raise an issue which is not concrete or litigable.
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Philadelphia Electric Company (Peach Bottom Atomic Power Station, Units 2 &
3), ALAB-216, 8 AEC 13, 20-21 (1974).
The purpose of the basis requirement of 10~ CFR Q 2.714 is to assure that the contention in question does not suffer from any of the-infirmities listed above, to establish sufficient foundation for the contention to warrant further inquiry of the subject matter in the proceeding, and to put the other parties sufficiently on notice "so that they will know at least gener-ally what they will have to defend against or oppose." Peach Bottom, supra 1
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An example of an issue which -is not proper for adjudication in a pro-ceeding is an issue-which is beyond the scopc of the proceeding or licensing action in question.
See, e33., Detroit Edison Company-j (Enrico Fermi Atomic Power Plant, Ur.it 2), LBP-78-11, 7 NRC 381 (1978).
r The Staff views the scope of the instant proceeding on renewal of an operating license to be nearly as broad as-a proceeding on initial 4
-issuance of an operating license.
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Fran the standpoint of basis, it is unnecessary for the petition "to detail the evidence which will be offered in support of each contention."
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!!ississippi Power & Light Company (Grand Gulf Nuclear Station, Units 1 & 2),
ALAB-130, 6 AEC 423, 426 (1973).
Furthermore, in examining the contentions i
and the bases therefor, a licensing board is not to reach the merits of the contentions.
Duke Power Company ( Amendment to Materials License SNM-1773 -
Transportation of Spent Fuel From Oconee Nuclear Station for Storage at
.McGuire Nuclear Station), ALAB-589, 9 NRC 146,151 (1979); Peach Bottom, i
supra at 20; Grand Gulf, supra at 426.
This principal was recently empha-L sized and reaffirmed in Houston Lighting & Power Company (Allens Creek Huclear Generating Station, Unit 1), ALAB-590,11 NRC 542, 548 (1980) where the-Appeal Board pointed out that, with regard to basis, all that is required at the petition stage is that the petitioner state the reasons for its f
contention.
4 In sum, at the petition stage, although a petitioner need not establish the
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validity of its contentions and the bases therefor, it is incumbent upon the petitioner to set forth contentions and the bases therefor which are suffi-ciently detailed and specific to demonstrate that the issues raised are admissible and that further inquicy is warranted, and to put the other parties on notice as to what they will have to defend-against-or oppose.
.This is particularly true where, as here, a hearing is not mandatory, in order to assure that an asserted contention raises an issue clearly open to adjudication.
Cincin$ati Gas & Electric Company, et al. (William H. Zimmer l
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..- Nuclear Power Station), ALAB-305, 3 NRC 8,12 (1976); Gulf States Utilities, Company (River Bend Station, Units 1 & 2), ALAB-183, 7 AEC 222, 226 at n.10 (1974).
The foregoing defines the principals for detemining the admissibility of CBG's proffered contentions.
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2.
Petitioner's Contentions Petitioner's contentions are divided into 23 major categories and, together with bases and~ background material, encompass over 130 pages of the supple-ment to the petition to. intervene.
In many instances, it is not entirely clear what' constitutes a contention ana what is intended to constitute the basis for the_ contention. To simplify its response, the Staff has _ extracted what appears to be the statement of each contention and set forth those
- contentions below. That portion of the material in the supplement to the petition to intervene which appears to be bases for, and arguments in support 4
of, contentions has not been. included in these statements of contentiors.
4 Statement of CBG Contention I The application - including the supporting appendices - is so substantially 1 flawed that it fails to meet even minimal standards for such applications and fails to adequately demonstrate that the health and safety of the public will be properly protected if the license is granted.
Specifically:
.(1) The. application omits essential infomation with regard to (a) experimental-vibration of the reactor, (b)' the present status of the reactor's manufacturer, and
- (c) UCLA's special nuclear material -license.
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- (2) UCLA failed to submit an original application as shown by (a) its submission of a 1980 Safety Analysis Report (SAR) which repeats virtually verbatim its 1960 Hazards Analy-sis, and (b) its submission of an environmental impact appraisal which repeats virtually verbatim the language of a 1974 AEC memorandum on " Environmental Considerations Regard-ing the Licensing of Research Reactors and Critical Facili ties. "
(3) The application contains misleading and inaccurate statements such as (a) the statement that the reactor will be used to support research at the M.S. and Ph.D level, (b) the statement that no structural weaknesses (earthquake vulnerability) have ever been identified, (c) the statement that no attempt has been made to alter the content and provisions of the earlier Technical Specifica-
- tions, (d) the statement that no deep wells have been drilled on the campus or in the vicinity of the campus, and (e) the statement that accidents ranging from failure of experiments to the largest core damage and fission product release considered possible result in doses of only a small fraction of 10 CFR Part 100 guidelines and are considered negligible with respect to the environment.
(4) The application contains unsupported and/or unsupportable state-ments as evidenced by (a) the statement there are no suitable or more economical alternatives which can accomplish both the educational and the research objections of the facility, and (b) the statement that the SPERT and BORAX tests showed that plate type fuel elements survived step radioactivity insertions of $3.54.
E Staff Position The Staff supports admission of Contention I, subparts 1.b,1.c, 2.a. 2.b,-
3.a. 3.b, 3.c, 3.e, 4.a. and 4.b on the grounds that these contentions
-satisfy the specificity and basis requirements of 10 CFR 9 2.714, and raise issues which are appropriate for consideration in this proceeding.
The Staff does not support admission of subparts 1.a and 3.d of Contention I on the ground that no basis has been provided for these contentions.
In subp3rt 1.a, CBG states' that while UCLA did indicate in its application that the reactor had been experimentally vibrated, UCLA did not indicate that the test had damaged.the reactor. CBG quotes an article by Craig B. Smith and R. B.11atthiesen in the magazine, fluclear Applications and Technology, Volume 7. July 196_, as suppor+ for its allegation of reactor damage and includes a copy of the re'<.vant magazine page in its Supplement to the Petition to Intervene. CBG's quotations indicate that more than six months after the vibration experiment, a safety blade stuck in the "out" position during a routine prestart checkout and that the subsequent reactor dismantling revealed upward displacement of the lead shielding bricks which caused bind-ing of the shaf t.
CBG failed to quote the next sentences in the article, which state:
"The lead shield blocks were stacked on lead shot which had
-been poured in the void spaces between the graphite and biological shield.
Subsequently, the lead shot has been canned.in steel containers, and a steel shroue has been welded in. place to protect the drive shaft from interference."
UCLA's failure to' state that experimental vibration of the reactor caused upward displacement of the lead shielding bricks does' not appear to be an t
omission of essential information because the problem was subsequently corrected. Thus, no basis is prnvided for Contention I.1.d.
In subpart 3.d of Contention I, CBG alleges that the application contains misleading and inaccurate statements because it says that there are no deep wells on the campus or in the vicinf ty of the campus.
CBG asserts that there are deep wells near the campus.
The basis for CBG's assertion is an unidentified map which it includes in its Supplement to the Petition to Intervene. This " map," however, is wholly unreadable and fails to show any deep wells. Therefore, the Staff concludes that the requisite basis for subpart 3.d of Contention I has not been presented and that the basis requirenent for that part of Contention I has not been met.
Statement of CBG Contention II The Applicant has applied for the wrong class of license. Applicant has applied for a Class 104 license despite the fact that in the past, more than fif ty percent of reactor funding and more than fif ty percent of the hours of reactor usage have been devoted to the sale of services, rather than research or education. Given this history, and without any indication that Applicant intends to change reactor usage, Applicant under 10 CFR 6 50.21(b) and 10 CFR 6 50.22 should have applied for a Class 103 license.
Specifically:
Applicant should apply for a Class 103 license because (a) Applicant's financial statements indicate that more than half of the reactor funding canes from sources other than the UCLA School of Engineering and Applied Sciences, cnd (b) the application indicates more than half cf the reactor oper-ating time is spent on commercial, non-educational projects.
I Staff Position The Staff supports admission of this contention on the grounds that it satisfies the specificity and basis requirements of 10 CFR s 2.714, and raises an issue which is appropriate for consideration in this proceeding.
Statement of CBG's Contention III Applicant has failed to demonstrate adequate managerial and administrative controls in the application, as required by 10 CFR 5 50.34(b)(6)(ii), and further, has demonstrated throughout its operating history grossly inade-quate controls. These inadequacies make it impossible to find that Appli-cant's managerial and administrative controls are adequate to responsibly protect the public hcalth and safety.
Specifically:
(1) Applicant failed to provide the infonnation required in 10 CFR s 50.34(b)(6)(ii).
(2) Applicant failed to get prior approval from the Reactor Use Com-mittee or the Reactor Director for changes in reactor systems and for non-standard experiments.
(3) Applicant failed to get prior Commission approval for facility changes.
(4) The Lab Director and/or Assistant Director were absent for exten-sive periods of time and provided inadequate supervision.
(5) Unlicensed visitors to the reactor facility were invited to operate the reactor controls in violation of 10 CFR Gs 50.54j, k,1, 55.2, 55.3a and b, SC.d and f, and 55.9a and b.
(6) Applicant kept inadequate records and lost a maintenance log, and (7) Applicant failed to hold administrative meetings and conduct reviews required by the Technical Specifications.
Staff Position The Staff supports admission of this contention on the grounds that it satisfies the specificity and basis requirements of 10 CFR 5 ?.714, and raises an issue which is appropriate for consideration in this proceeding.
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Statement 1of CBG Contention IV Applicant has been-consistently cited for violations of NRC regulations as well-as violations of the provisions -of its own Technical Specifications.
This consistent pattern of regulatory non-compliance and the lack of assur-ances that the' pattern will not continue in the future indicates that the Applicant cannot adequately demonstrate that future operation of-the. facility will_ ~ comply satisfactorily with the regulations to protect the public health and safety.
Staff Position The Staff supports admission of this contention on the grounds that it satisfies the specificity and basis requirements of 10 CFR Q 2.714, and raises an issue which is appropriate for consideration in this proceeding.
Statement of CBG Contentica V The amount of excess reactivity which is pemitted by the Technical Specifi-cations to be installed'in this reactor is-too great in that it is poten-tially sufficient to cause a serious power cxcursion which could bring about melting of the fuel cladding and significant release of fission products, seriously endangering the public health and safety.
Specifically:
(1) The amount of excess reactivity must be limited in such a way as.
to ~ provide a large margin of safety.
(2) -The reactor has lost several significant self-limiting features in that
~(a) the level of excess reactivity _has been changed so that
.it is now higher than that needed for prompt criticality, (b) a' deflector plate which prevented repeated excursions has been removed, (c).the assumption that there is a large negative temperature coefficient appears to be wrong in light of information regarding a positive graphite temperature coefficient, and
~(d) the reactor's power level has been. increased from 10 Kw to 100 Kw.
'(3) Excess reactivity is now more than that needed for prmpt criticality.
'(4) _The licensed amount of excess reactivity (2.3%
k/k) could cause melting of the fuel cladding according to the 1960 Hazards Analysis.
(5) The reactor's void coefficient has changed since the initial calculations were done.
(6) Through the conversion of 2.3% k/k as the excess reactivity limitation.in the current Technical Specifications to $3.54 in the proposed Technical Specifications and the use of a different froa that used in the Hazards Analysis, the Applicant may have changed the limitation from 2.3% to 2.62%, thus presenting the potential for a serious excursion and melting of the cladding.
(7) The assumption that the BORAX I test results can be extrapolated to the UCLA reactor is incorrect.
(8) Graphite has a positive temperature coefficient.
.(9) Applicant's data is twenty-five years old and thus, by virtue of its age, creates more uncertainties.
(10) Applicant's Hazards Analysis regarding excess reactivity is based on unverified and unidentified assumptions which can be.used merely to estimate a range of excess reactivity additions and their possible hazard. Additionally, Applicant has not provided error bars for its computations and analyses.
(11) The reactor now uses a pneumatic " rabbit" system for rapid inser-tion:of excess reactivity which it did not use when the reactor was built.
(12) The licensed limit on combined experiments --
$3.54 -- could cause.a catastrophic accident.
(13) Removal of'a beam tube could cause insertion of excess reactivity into the reactor because neutron absorption would be removed and reflection savings would be--increased.
(14) There is no adequate review of how the increase in power level i
from 10 'Kw to 100 Kw might affect excess reactivity.
(15) Applicant has violated excess reactivity limits suggesting it is
' impossible 'to prevent ^ possible excursions.
.(16) The Borax data needs error bars.
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- (17) Applicant failed to analyze the possibility of euctectic melting.
(18) The problem of excess reactivity is exacerbated by other related safety and _ operation problems such as (a) Applicant's history of inaccurate instrument calibration, (b) Applicant's history of unscheduled shutdowns, (c) problems with the pneumatic tube system, (d) Applicant's history of lax administrative and managerial
- controls, (e) Applicant's history of bypassing interlock and safety
- systems, (f) problems with the control blades, (g) positive temperature coefficient of graphite moderation
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negates reactor's inherent self limiting ' features, (n) lack of airtight containment and siting in a crowded building on a crowded campus, (i) presence of only four control blades and the lack of back-up blades, (j) heat balance problem and long-tena stabilization of neutron channels problem, (k) graphite' swelling and cracking, (1) fuel blade warping', and (m) lack'of a deflector.
Staff Position
. The Staff supports admission of subparts 2.a, 2.b, 2.c, 2.d, 4, 5, 6, 7,10,
- 11,12,13,15,17,18.a,18.h,18.1,18.j,18.k, and 16.1 of this con-tention on the grounds that they satisfy the. specificity and basis require-ments of 10 CFR @ 2.714, and raise issues which are appropriate for consid-eration-in this proceeding.
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The Staff opposes admisison of subparts 1, 3, 8, 9, 14, 16, 18.b, 18.c,
18.d,-18.e 18.f.18.g, and 18.m on the grounds that they either lack an
' adequate basis or that they replicate another subpart in Contention V or another contention in CBG's Supplemental Contentions. The Staff will explain its opposition.to these subparts seriatim.
First, Contention V states broadly that the amount of excess reactivity pennitted by the Technical Specifications is too great in that it could cause a serious power excursion.
Subpart 1 does not provide a basis for this assertion because it does not establish why the excess reactivity is too great but merely states that the safety margin should be large. CBG's statement that the safety margin should be large is not even supported by i
j the document it cites for that purpose.
Page 19 of the Hazards Analysis l
. merely states.that the " total available excess reactivity [should] be limited l
to somethi'ng less than that needed for prompt criticality." (emphasis I
added).. While the need for large safety margins may be legitimate, a state-ment of that need does not substantiate CBG's assertion that the Technical Specifications' pennit too much excess reactivity. -Thus, subpart I should be rejected.
l Second, subpart 3 which statesL that the excess reactivity pennitted in the l:
reactor. is no longer:less than that needed for. prompt criticality is essen-i tially' the same as subpart 2.a ~ hich states that the reactor has lost a l
w self-limiting feature because excess reactivity has been increased above the F
' level necessary for pronpt criticality.
Because the' detailed discussion of i
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'CBG's' concern which accanpanies subpart 3 and provides its basis is equally applicable to subpart 2.a. the Staff supports admission of subpart 2.a ratherJthan subpart 3 because subpart 3 is repetitive.
Thus, it should not be admitted.
Third, subpart 8 states -that the assumption that there is a large negative temperature coefficient appears to be wrong in light of information regard-
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ing a positive graphite temperature coefficient. This allegation, while unsupported in subpart 2.c, is explained at length in subpart 8.
Because the subparts are essentially the same, the basis provided with subpart 8 applies equally to each of them. Thus, subpart 8 is repetitious and should not be admitted.
-Fourth, subpart 9 asserts that because Applicant's data (i.e., Hazards
- Analysis) is twenty-five years old, by virtue of its age, it creates addi-tional uncertainties. The thrust of this assertion, then, is the same as the gist of Contention I.2.a.
Furthermore, this contention is advanced in support of the assertion that the reactor's Technical Specifications permit too much excess reactivity. On its face, subpart 9 seems to say that CBG cannot determine by using the 1960 Hazards Analysis whether tne Technical
-Specifications permit too much excess reactivity or not. The age of the Hazards Analysis, in and of itself, is not relevant to the issue of whether the Technical -Specification limits on excess reactivity are inadequate.
' Accordingly, subpart'9 of this contention should be rejected..
Fifth, the assertion in subpart 14 that there has been no analysis of the effect of an increase in the power level from 10 Kw to 100 Kw on excess reactivity is essentially the same as the assertion in item 2.d.
- Thus, subpart 14 is duplicative and should be rejected.
Sixth, subpart 16 states that the Borax data needs error bars. The basis advanced for this contention is CBG's conce rn that the data points charted for Borax in the Hazards Analysis may :.ac be as firm as they would like.
The existence of error bars, however, is irrelevant to the issue of whether-the Technical Specifications permit too much excess reactivity.
Ins tead,
CBG's concern regarding error bars for the Borax data appears to be a component of its concern regarding the applicability of Borax data to the UCLA reactor. Thus, subpart 16 should be rejected because as explained by its basis, it repeats CBG's concerns found in Conter. tion V.7.
Seventh, subpart 18.b states that the excess reactivity hazards could be exacerbated by Applicant's history of unscheduled shutdowns. The basis for this contention-is CBG's assertion that incorrect procedures may permit unsafe withdrawal' of samples from beam tubes.. CBG's Contention 7 deals with Applicant's history of unscheduled _ shutdowns. The shutdowns referenced there are allegedly caused by incorrect procedures or by failure to follow 1
correct procedures which relate to reactor operation. The procedures which relate to removal of samples from beam tubes are unrelated to the _peocedures which ' caused the. unscheduled shutdowns ' referred to by CBG in Contention 7.
Because subpart 18.b refers to two different sets of procedures, one of ~ them
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appearing to~ be unrelated to excess reactivity, it is unclear what the thrust of CBG's statement is. This contention is confused and not under-
.standable 'and, as presently constituted, does not alert 'the parties as to what they must be prepared to address.
Thus, the Staff opposes admission of 18.b in its present form as a subpart of Contention V.
Eighth, subpart 18.c. states that Applicant's problems with the pneumatic tube system could result in a large reactivity insertion. This is essentially a restatement of subpart 11 which notes that the reactor now uses a pneumatic
" rabbit" systen tnat provides for the. rapid insertion of a sample of positive worth as well as negative worth. Because subpart 18.c merely states there is a problem, without more, and because subpart 18.c duplicates subpart 11, the
- Staff opposes admission of this subpart on the ground that it is repetitious.
Hinth, in subpart 18.d, CBG states that Applicant's history of lax admin-istrative and managerial controls such as inviting unlicensed persons to l
operate the-reactor exacerbates the excess reactivity hazard. CBG does not, y
i however, explain how this could happen. Because subpart 18.d is unclear on its face and is not explained anywhere in the Supplement to the Petition to Intervene, the Staff opposes.its admission on the grounds that it lacks the
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i requisite specificity and basis and does not alert-the parties as to what
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they must defend against or oppose.
5 Tenth, subpart 18.e: states that Applicant's history of bypassing interlocks and safety systems'could exacerbate the excess reactivity problem.- Because
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this assertion is not accompanied ~by any additional 'information, it is not clear why or on-what grounds CBG believes bypassed interlock and safety systems could exacerbate the excess reactivity problem. Thus, the Staff opposes admission of subpart 18.e on the ground that no basis has been provided 'for it and because it does not alert the parties as to what they must be prepared ~to address.
Eleventh, subpart 18.f states that Applicant's troubles with control blades could exacerbate 'the excess reactivity problem. As its basis, CBG asserts that because of these control blade problems, there is an unacceptable likelihood fat 10 CFR Part 50, Appendix A guidelines for reactivity control systems cannot be met.
CBG does not explain why control blade problems could exacerbate the excess reactivity problem. CBG merely asserts that, without elaboration. As an aside, it should be noted that Appendix A to 10 CFR Part 50 applies only to nuclear power reactors. The Staff opposes admission of this subpart on the ground that CBG's ' failure to explain how this alleged problem could affect the excess reactivity problem renders subpart 18.f defective due to lack of the requisite basis.
Twelth, subpart 18.g. states that the excess reactivity problem could be.
exacerbated by the positive temperature coefficient of graphite. Howeve r, subpart 3 of this contention states'that there is an excess reactivity problem because graphite has a positive 'tsnperature coefficient.
Effec-tively, then, CBG is arguing that the positive temperature coefficient of
. graphite which causes an excess reactivity problem could be exacerbated by p
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the positive terperature coefficient of graphite. The Staff opposes admis-sion of this subpart on the ground that;it _is confused and repetitive.
s Statement of CBG Contention VI A' plicant has in the past and is at present emitting excessive radiation, p
violating radiation standards, and conducting' inadequate monitoring. Appli-cant has failed to demonstrate-in its application or in its recent perform-ance any evidence that these conditions can reasonably-be expected to improve in the future, in the absence of which demonstration grant of an operating and SNf1 license cannot be made without undue threat to public health and safe ty.
Specifically:
r-(1) Past and present emissions are excessive.
i (2) Several conditions which cause present emissions to be excessive have not been changed; therefore, excessive emissions can be expected in the future.
(3) Applicant has not in the past nor in the present application been i
able.to reasonably demonstrate that exposure in unrestricted areas is not excessive because it lacks an adequate radiation monitoring system.
(4)
Applicant presently (does not canply with the radiation standardsin 10 CF l
and 100.
l Staff Position The Staff supports admission-of this contention on the grounds that it satisfies the specificity 'and' basis' requirements of 10 CFR 5 2.714, and raises an issue which is appropriate for consideration in this proceeding.
-Statement of CBG Contention-VII The reactor has in the past experienced a persistent pattern of numerous unschedcled shutdowns, abnormal-occurrences, and accidents. These occur-rences are/so pervasive that they evince a pattern of unreliability which makes it impossible for Applicant to reasonably assure that the reactor can be. operated in _a-manner which. does not endanger the public health and safety.
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Staff Position The Staff supports admission of this contention on the grounds that it satisfies the specificity and basis requirements of 10 CFR 5 2.714, and raises an issue which is appropriate for consideration in this proceeding.
Statement of CBG Contention VIII The Applicant has failed to meet the siting criteria of 10 CFR Part 100 regarding radiation exposure in case of an accident.
The calculations contained in the SAR are. based _on numerous assumptions that unrealistically
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minimize the extent of exposure in case of a major release of fission prod-ucts, and that even with these unrealistic assumptions,- Applicant's own SAR indicates that it is in violation of 10 CFR Part 100 standards for thyroid dose -to the public in case of a major accident. The standards set a limit of 300 rem for thyroid exposura (10 CFR 55100.11(a)(1) and (2)) and the application shows the possible dose from a reactor accident is 1800 rem for thyroid dose.
Specifically:
(1) ' Applicant's SAR indicates an accident would cause public exposures
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in excess of the limits in 10 CFR 5100.11(1) and (2).
(2) The safety analysis is flawed because (a) ' Applicant assumes a release limited to only 10% of the volatile fission products and none of the non-volatile
- products, (b) Applicant assumes the reactor has been operated at 10 Kw long enough to have attained equilibrium concentrations of relatively short-lived fission products, (c) Applicant assumes the reactor is in a two-story building with possible exposure to the public occurring outside the building,
'(d) Applicant assunes a building leakage rate of 20% of the reactor room-volume per hour for a 30 mile per hour wind, assumed to be directly proportional to wind velocity, and (e) Applic. ant has not tested any of the assumptio.ns upon which the analysis is based and new dose and dispersion models are now available.
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. Staff Position The Staff opposes admission of this contention on the ground that it appears to be a challenge to the regulations.
Part 100 expressly applies to stationary power and -testing -reactors subject to 10 CFR Part 50.
10 CFR s 100.1(a).
To the extent that CBG is asserting that the regulation should cover research reactors and thus more than it presently does, it is inadmissible.
-Statement of CBG Contention IX The Applicant in the past has not adequately maintained its equipment nor calibrated its instruments properly, thereby increasing the chances of equipment failures and erroneous instrument readings. Applicant has failed to demonstrate that its maintenance and calibration effort will improve in the future. This failure precludes the conclusion that the issuance of the license will not be inimical to the public health and safety.
Staff Position The Staff opposes admission of Contention IX on the ground that it is merely a restatement of Contention V.18.a.
As such, it is repetitive and should be rejected.
Statement of CBG-Contention X The Environmental-Impact Appraisal submitted by Applicant is lacking in detail, largely. copied from material not related to this particular facility, relies on unsupported assumptions and conclusions,-and is generally so inadequate that it cannot possibly support the issuance of a license or support the finding-by the Commission that the licensing. is not an action
. that significantly.affects the quality of the human environment.
Speci f-
-ically:
(1)- The application lacks an original environmental impact appraisal
.for the UCLA reactor.
(2) The analysis of the environmental effects of facility operation is inadequa te.
(3) The analysis of the envirorv. ental effects of accidents is inadequate.
(4) The application does not contain a discussion, analysis, or descrip-tion of alternatives to the reactor's operation.
(5) The application's discussion of the reactor's long tem effectsi ~is conclusory and inadequate.
(6) The application's discussion of the reactor's costs and benefits is inadequate and conclusory.
Staff's Position The Staff opposes admission of this contention as it is presently drafted on the ground that it is a challenge to a regulation.
Part 51 of Volume 10, Code of Federal Regulations, imposes on the Commission the duty to prepare detailed environnecetal statements on major Federal actions significantly affecting the environment.
Part 51 does not impose on Applicant the duty either to prepare an environmental impact statement or an environmental inpact appraisal. To the extent that Contention X asserts that Applicant shou ~.3 submit such documents, it is a challenge to Part 51 and is thus inadmissible.
However, to the extent that Contention X asserts that Appli-cant has not submitted the environmental infonnation required by 10 CFR 5 50.34(b)(1) or that the submitted infonnation is inadequate, the conten-tion would be admissible.
Statement of CBG Contention XI The UCLA research reactor lacks key intrinsic and engineered safety features and other safety features are substantially inadequate; particularly lacking are features that are redundant and independent.
Furthemore, a number of safety features. built into the reactor initially are no longer existent.
Specifically:
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(1) ' The intrinsic safety features of the reactor have been substan-tially' mitigated or removed.
For example,
-(a) although believed to be negative at the. time the react 5r
!was built, sthe temperature coefficient of graphite is now known to be positive, and (b) the deflector shields apparently have been removed.
(2) -The engineered safety features are inadequate to protect the public health and safety.
For example, j.
(1) the reactor does-not have an airtight containment structure, (2) the high level radiation monitor system is inadequate, (3) the reactor does not have an adequate Faron-injection
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system, a radioactivity removal systr,m, emergency liquid l
and gaseous emissions holding tare, HEPA filters, an
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emergency core cooling system, an emergency set of control blades, or spare control blade motors, (4) the reactor lacks adequate shielding and access restrictions in areas where the public might be exposed to radiation, (5) the reactor has inadequate or non-existent interlock
- systems, (6) the reactor lacks missile shields, particularly for control blade drives, (7). graphite used -in reactors has a tendency to swell and
'thus poses a hazard, l
(8) the reactor has a history of fuel failures, particularly tie bolt. failures, and (9).the reactor has a history of control. blade problems.
g Staff Position
.The Staff supports admission of Contention XI, subparts 2(3),2(4),2(5),
I 2(6), 2(7), 2(8) and' 2(9) on the grounds that.these contentions satisfy the L
specificity and basis requirements of 10 CFR $ 2.714, and raise issues which are appropriate for consideration in' this. proceeding.
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The Staff does not support admission of subparts 1.a,1.b, 2(1), or 2(2) of Contention XI on the ground that they replicate subparts of other contentions in CBG's Supplemental Contentions. lhe Staff will explain its opposition to these subparts seriatim.
First, Contention XI.1.a is a restatement of the contention and basis alleged in Contention V.2.c.
Contention XI.1.b repeats Contention V.2.b.
Contention XI.2(2) is the same as Contention VI.3.
Because Contentions XI.1.a. XI.1.b, and XI.2(2) are duplicative and repetitious, the Staff urges that they be rejected.
Contention XI.2(1) repeats the statement of contention found in Contention V.18.h but goes on to provide a basis for this assertion.
In view of the fact that V.18.h and XI.2(1) are the same allegations, the basis provided in XI.2(1) is equally applicable to V.18.h.
The Staff supported admission of V.18.h; thus, it opposes admission of XI.2(1) on the ground that it is duplicative and repetitious.
Statement of CBG Contention XII The Applicant's equipment, facilities, and procedures for handling and using special nuclear materials are inadequate to protect health and minimize danger to life and property and therefore cannot support the-issuance of a license.
Specifically:
(1) ' Applicant does not include an application for a special nuclear materials license with its application for renewal of its operating license.
(2) That infonnation which Applicant has provided regarding the special nuclear materials license is inadequate and does not fulfill the
- requirements of 10 CFR QS 70.22 and 70.33.
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(3) Applicant's ' general safety, security, and operating history suggest that the license for bomb-grade (93% enriched) uranium should not be granted.
For_ example, (a) Applicant's-failure to notify local authorities and its inability to keep information secret when it shipped spent fuel on June 21,-1980, indicates that Applicant is unqualified to handle either fresh or spent fuel.
Staff's Position The Staff supports admission of Contention XII, subpart 3.a on the grounds
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that it satisfies the specificity and basis requirements of 10 CFR @ 2.714, i
and raises an issue which is appropriate for consideration in this proceeding.
The Staff opposes admission of subparts 1 and 2 on the ground that they merely replicate sub, art 1.c of Contention I.
Thus, as subparts 1 and 2 are duplicative and repetitious, the Staff urges their rejection.
Statement of CBG Contention XIII Problems inherent in the design of Argonaut type reactors have been identified at other Argonaut reactor facilities, and until Applicant has demonstrated that these problems have been adequately resolved at UCLA, the Applicant cannot assume that the operation of the reactor will not be inimical to the public health and safety.
Specifically:
(1) The positive temperature coefficient of graphite increases the likelihood of a reactor runaway and decreases the effectiveness of the reactor's self-limiting features.
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'(2) Other Argonaut facilities have had control rod motor problems and therefore UCLA should have replacement motors on site.
(3) Because the University of Florida's Argonaut coolant system has
- had water _ pressure problens, UCLA's reactor coolant system should have. a pressure conpensation system installed.
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Staff Position The Staff supports admission of Contention 'XIII, subpart 2 on the grounds that.it satisfies the specificity and basis requirements of 10 CFR 9 2.714, and raises an issue which is appropriate for consideration in this pr'oceeding.
The Staff-does not support admission of subpart 1 on the ground that it
- replicates Contention V.2.c.
Thus, subpart 1 is duplicative and should be rejected.
Further, the Staff does not support admission of subpart 2 on the ground that it replicates Contention V.18.i.
It should be noted that while CBG ~ states that its concern is with control rods or blades, the basis stated for that concern-at Contentions.V.18.f and V.18.i as well as XIII.2 is references on the need for back-up motors. Thus, subpart 2 should be rejected as repetitive.
Statement of CBG Contention XIV
.The site characteristics of this reactor such as population density and seismic activity are such, and have changed sufficiently over the period of the first license, that the reactor cannot be operated in such a manner as to assure that the public health and safety will' be protected. 'Specifically:
(1) The population density. immediately_ surrounding the reactor and-in the general vicinity of the reactor has increased substantially
.since the _ reactor. was licensed.
(2). The reactor does not comply with 10 CFR Part 100 siting criteria.
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(3) The reactor is sited in a seismica'lly active area and has been damaged by seismic activity in the last twenty years',
' Staff. Position The Staff supports admission of Contention XIV, subparts 1 and 3 on the grounds' that they satisfy the specificity and basis requirements of 10 CFR
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6 2.714, and raise. issues which are appropriate for consideration in this proceeding.
The Staff'does not support admission of subpart 2 because it replicates Contention VIII. Thus, it is duplicative and should be rejected. The Staff notes, however, that Contention VIII (if redrafted because it presently constitutes a challenge to 10 CFR Part 100), Contentions. XIV.1 and XIV.3, and Contention XVIII (to be discussed later) raise different aspects of CBG's concern with reactor siting. Therefore, the Staff recommends consoli-dation of these three contentions.
Statement of CBG Contention XV i
The reactor in question is so old that it poses an. unacceptable hazard should it be relicensed, particularly for a twenty-year period. The key equipment is already so aged as-to be unreliable and other equipment is antiquated _and outdated.
Because of the age of the reactor it is very
-difficult to obtain spare parts and key safety featu_res required of newer facilities are lacking in this facility. The reactor is thus too old to function safely and reliably now, let a'c a at the beginning of the next cen tury.
Specifically:
(1) The reactor was built in thr: 1950's by a company which is no longer in the reactor businsss.
(2) The age of the reactor makes instrumentation unreliable, difficult to repair, and difficult to replace.
(3) Much equipment is outdated and, because Applicant does not have the financial means to update it, it is likely to get worse.
(4)~ The reactor was built before containment vessels and emergency core cooling systems were determined to be important.
(5) The reactor was built before recognition of the Argon-41 problem.
(6) Age has-severely reduced the reactor's usefulness.
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Staff Position The Staff supports admission of Contention XV, subparts 2, 3, and 6 on the grounds that they satisfy the specificity and basis requirements of_10 CFR
$ 2.714, and raise issues which are appropriate for consideration in this proceeding.
The Staff opposes admission of subparts 1, 4, and 5 on the ground that they replicate other contentions.
Subpart I repeats the assertion and basis of Contention I.1.c.
Subpart 4 repeats CBG's concern as stated in Contention XI, subparts 2.1 and 2.3.
Subpart 5 replicates Contention VI. Because subparts 1, 3, and 5 are duplicative, the Staff urges their rejection.
Statement of CBG Contention XVI The facility for which the license has been requested is inadequately protected from seismic activity.
Furthermore, there is a basis for concern that the facility is vulnerable to seismic activity and its location is one of the most seism lcally active regions of the country. The reactor therefore poses a serious threat to public health and safety.
Specifically:
(1) Applicant has omitted key information from the application regarding seismic vulnerability.
(2) The application simply repeats the language of the 1960 Hazards Analysis and does not consider new infomation.
(3) -The application does not contain a thorough review of potential seismic problems.
Staff Position The Staff supports admission of Contention XVI, subpart 3 on the grounds that it satisfies the specificity and basis requirements of 10 CFR 6 2.714,
.and raises an issue which is appropriate for consideration in this proceeding.
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The Staff opposes admission of subparts 1 and 2 of Contention XVI on the ground that they replicate other contentions. The two bases for CBS's concern regarding anission of information from the application are recognized in Contentions I.1.a and I.3.b.
Supart 2 is the same as Contention I.2.a.
Thus, Contentions XVI.1 and XVI.2 are duplicative and should not be admitted.
Statenent of CBG Contention XVII The Applicant does not _ possess and cannot give reasonable assurance of obtaining funds sufficient to cover the costs of operating the facility over the twenty year license period plus the cost of permanently shutting the facility down and maintaining it in a safe condition.
Given this lack of assurance, Applicant fails to qualify financially for an operating license.
Specifically:
(1) Applicant has deferred maintenance in the past due to lack of funds.
(2) applicant, as part of a public institution and subject to yearly funding, cannot assure that it will obtain sufficient funding for operation or decommission over the license period.
(3) Applicant has not shown that it will be able to obtain funds to cover the decommissioning cost of the reactor.
Staff Position The Staff supports admission of Contention XVII.1 on the grounds that it satisfies the specificity and basis requirements of 10 CFR S 2.714, and raises an issue which is appropriate for cor ideration in this proceeding.
The Staff opposes admission of Contention XVII.2 on the ground that it constitutes a challenge to a NRC regulation.
Section 50.33(f) of volume 10, Code of Federal LPegulations, states, in pertinent part:
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Each application shall state:
(f)
Infomation sufficient to demonstrate to the Commission the l financial qualifications of the applicant to carry out... the activities for which the... license is sought..... If the application is for an operating license', such information shall show that the applicant possesses the funds necessary to cover estimated operating costs or that the applicant has reasonable assurance of obtaining the necessary funds, or a combination of the two.
(emphasis added).
As presently drafted, Contention XVII.2 appears to require UCLA to show that it has sufficient funds to cover decommissioning of the reactor. The regula-tion merely requires UCLA to show that it has sufficient funds to cover operating costs. To the extent CBG argues that UCLA should have to show more than the regulation requires, it is an attack on the regulation and as such is impemissible.
Thus, Contention XVII.2 should be rejected.
The Staff also opposes admission of Contention XVII.3 on the ground that it
-challenges f1RC regulations. The reasoning stated above applies with equal force to this Contention and thus it should be rejected.
Statement of CBG Contention XVIII Because of the placement of this reactor in a crowded building on a highly populated campus in a highly populated urban area, and because of the lack of a containment structure'to ' effectively isolate fission products that might be released in an accident, and because the reactor is operated in an instructional and -training situation, it is essential that a thorough analysis
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be conducted of.-various possible scenarios by which a major accident might occur. fio attempt has been made in the Application to consider the maximun credible accident for this facility.
Specifically, the following scenarios should be t xamined thoroughly:
-(1) an earthquake which causes fission product release by damaging the core 'and breaking open the fuel, m
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'(2) sabotage _ from a person within the University and from an outside
- person, (3) reactor runaway, (4) a plane crashing into the reactor building, (5) multiple failure modes, (6) maximum potential operator error, and (7) other failure modes which can best be determined by Applicant af ter discovery.
Staff Position The Staff supports admission of subpart 1 of Contention XVIII on the grounds that it satisfies thc specificity and basis requirenents of 10 CFR Q 2.714, and raises an issue which is appropriate for consideration in this proceeding.
With the. exception of subpart 2, however, the Staff concludes that the remaining postulated accidents lack the requisite specificity to apprize the parties to this proceeding as to what they should be prepared to address.
In addition to lacking the requisite specificity, subpart 2 which relates to sabotage is outside the scope of-the proceeding to the extent that it asserts that UCLA must do more 'than comply with applicable requirements of 10 CFR Part 73. Thus, th' Staff opposes admission of. subparts 3, 4, 5, 6, and 7 of Contention XVIII on the ground that they are not cufficiently specific and
.of subpart 2 on the ground that -it lacks the requisite specificity and raises an issue outside the: scope of the proceeding.
Statement o'f CBG Contention XIX i
Applicant's Physical Security Plan is' inadequate and fails to meet-the i:
requirements set forth in 10 CFR 6 50.34(c).
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Staff Position The Staff opposes admission of Contention XIX on the ground that no basis has been provided.
CBG' asserts two bases for this contention:
(1) a shipment of high level waste fraa the reactor was discovered by the-local news media and (2) Appli-cant has a history of inviting and allowing unlicensed persons to operate the reactor.
First, section 50.34(c) on its ' face does not apply to the shipaent of spent fuel from a reactor. Thus,- CBG's first basis' is inadequate to support Contention XIX.
Second, CBG's assertion that Applicant has a history of inviting and allowing unlicensed persons to operate the reactor does not indicate anything about the security measures taken for those persons.
Furthermore, the materials cited by CBG do-not establish that Applicant has ever allowed an unlicensed person to operate the reactor. To the contrary, the materials establish-that UCLA twice requested in writing and once by telephone permission for Open House visitors to operate the reactor. The Commission denied these requests, all of which occurred in 1966, and it appears froa the references that UCLA complied with NRC. instructions.
Beyond that, CBG cites an April 9, 1979, letter to Michael Douglas irviting him to visit the UCLA reactor and ope ra te - i t.
Again, CBG has merely established that an unlicensed person was invited to operate the. reactor and has failed to indicate what security precautions would have been taken in the event that any' unlicensed person
- did. operate the reactor. Thus, CBG's second basis is inadequate to support
- Contention XIX.
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The Staff notes, however, that it is very difficult, if not impossible, for CBG to frame a contention which is specific and to support it with an adequate basis because infonnation regarding the physical security plan is not readily available to the public. Thus, the Staff recommends that the Licensing Board defer ruling on the admissibility of Contention XIX until the Staff has had a chance to meet with CBG and to inform CBG of flRC's regulatory requirements regarding physical security plans. The Staff will then report to the Board whether CBG's concerns have been assuaged or whether CBG wishes to fonnulate a specific contention.
Statement of CBG Contention XX Applicant's Emergency Response Plan is insufficient to demonstrate that the plan provides reasonable assurance that appropriate measures can and will be taken in the event of an emergency to protect public health and safety and prevent damage to property.
Staff Position The Staff supports admission of Contention XX on the grounds that it satisfies the specificity and basis requirements of 10 CFR 9 2.714, and raises an issue which is appropriate for consideration in this proceeding.
Statenent of CBG Contention XXI Applicant has not submitted a safeguards contingency plan as part of their apolication and therefore the plan is inadequate and cannot support the issuance of a license.
Staff Position At the outset, the Staff notes that Contention XXI is on its face confused and illogical.
First, CBG asserts there is no safeguards contingency plan;
A then ^ it saysithe. plan is inadequate. 'The Staff believes that CBG's contention either alleges that the application is inadequate for failure to include a safeguards contingency plan or that-the_ safeguards contingency plan submitted does not' meet the requirements of.10 CFR.9 50.34(d). The Staff further notes that the basis' asserted by:CBG in support of Contention XXI -- the inadequate nature of'the application and Applicant's history of lax security practices -- is-inadequate -because unrelated to the specific aspects of a
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safeguards contingency plan. Thus, the Staff opposes admission of this contention on the grounds that the requisite specificity and basis mandated by 10-CFR 9_2.714, has not been provided.
The Staff recognizes, however, that it is very difficult for CBG to frame a specific contention and to provide adequate basis therefor because the relevant information is not readily accessible to the public. Most of the information regarding safeguard contingency plans is protectible under 10 CFR 9_2.790 and may even be classified information. Thus, the Staff recommends that the Licensing Board defer ruling on the admissibility of
- Contention XXI until -the Staff has had an opportunity to meet with CBG regarding NRC regulatory. requirements for safeguard contingency plans.
The Staff will then re. port to the Board whether CBG's concerns have been assuaged or whether CBG wishes to submit a specific contention.
- Statement of CBG Contention XXII The Technical Specifications-included in the application contain provisions which unacceptably reduce safety standards and pose a threat to public health and. safety;. numerous substantial changes have been made in the Techni-ical Specifications without so describing in the introduction.
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Staf f' Fosi tion The Staff opposes admission of Contention XXII..on the ground that it repli-cates Contention I.3.c.
Thus, as Contention XXII is merely duplicative of an earlier assertion, the Staff urges its rejection.
Statement of CBG Contention XXIII (1) Because Applicant has indicated in the application, in newspaper articles, and elsewhere that it wishes to increase operating hours and power, NRC consideration of the proposed changes'should be consolidated with the licensing renewal procedure.
-(2) A twenty -year license period is excessive considering the present age, condition, and design of the reactcc.
Staff Position The Staff opposes admission of Contentions XXIII.1 and XXIII.2 on the ground l
that they both are completely lacking in' basis. CBG cites nothing to show where in the application, in which newspaper, or where else Applicant has l
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l Indicated its intent to increase the ~reacter's operating hours and power level. Because Applicant has not requested an increase in the hours of l
operation and power level of the reactor, such matters are not a part of tue license. renewal application in question. Thus, CBG's contention falls outside the scope of this proceeding and should be rejected.
CBG also fails l
to provide any foundation for its belief = that the reactor should not be
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licensed for a twenty year term. Thus, as Contention XXIII.2 is merely a statement of CBG's opinion, without more, the Staff urges its rejection for
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lack of the requisite basis.
C.
Conclusion Based on the foregoing, the Staff concludes that CBG has submitted at least une good contention and thus should be admitted as a party to this proceeding.
The Staff urges that the Licensing Board rule on the admissibility of CBG's contentions in a fashion consistent with the Staff's position in this document.
Respectfully submitted,
,/
.s DT14G L N
L Jessica H. Laverty Counsel for NRC Staff Dated at Bethesda, liaryland this 16th day of September,1980 3
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.o-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket No. 50-142 THE REGENTS OF THE UNIVERSITY OF
)
)
(Proposed Renewal of Facility
)
License)
(UCLA Research Reactor)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S POSITION ON CONTENTIONS OF COMMIT-TEE TO BRIDGE THE GAP".in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear _ Regulatory Commission's internal mail system, this 16th day of Sept aber, 1980:
Elizabeth S. Bowers, Esq., Chairman
- James W. Hobson, Vice Chancellor Atomic Safety and Licensing Board
& Responsible Officer U.S. Nuclear Regulatory Commission University of California at Washington, DC 20555 Los Angeles 4t5 Hilgard Avenue Dr. Epimeth A. Luebke, Member
- Los Angeles, CA 90024 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. John Bay Washington, DC 20555 1633 Fri.nklin Street Dr. Oscar H. Paris, Member
- Atomic Safety and Licensitig Board Mr. D'On Voelyke U.S. Nuclear Reg"1 ? tory Commission c/o University Religious Washington, DC iMS Conference 900 Hilgard Avenue Dr. Walter F. Wegst Los Angeles, CA 90024 Office of Research &
Occupational Safety Ms. Marjorie J. Woolman University of California Secretary of the Regents at Los Angeles 689 University Hall 405 Hilgard Avenue Berkeley, CA 94720 Los 41geles, CA 90024 Committee to Bridge the Gap 1637 Butler Avenue,-#203 Los Angeles, CA 90025
e Mr. Steven R. Tekosky Atomic Safety and Licensing Board Environmental Section Panel
- 200 North Main Street U.S. Nuclear Regulatory Commission City Hall East, Room 215 Washington, DC 20555 Los Angeles, CA 90012 Docketing and Service Section (7)*
Atomic Safety and Licensing Appeal Office of the Secretary Panel (5)*
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 oicaY.!avcAbf CounselforNRCStaff_J Jessica H. Laverty I
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